Anritsu Group Code of Conduct

Chapter1: General Provisions

1.1 Essence of Anritsu Group Code of Conduct

To increase corporate value of a company, it is essential for all the employees, including managements
(referred to as "we", "us", and "our" hereafter), to truly realize the social responsibility of the company,
abide by relevant laws and regulations in every aspects of corporate activities, and to act in accordance
with the social ethics. This Anritsu Group Code of Conduct (hereinafter the “Code”) provides the
guideline of conducts which we should bear in mind in our daily business operation, aimed to assure that
Anritsu Group is consistently being an ethical corporate group.

This Code exemplifies fundamental ethical views and typical corporate guidelines, but does not cover all
the circumstances that may arise. In each individual situation, we should judge "Fairly", and act with
"Sincerity" by fully understanding relevant laws and the spirit of this Code.

1.2 Basic Attitude

This Basic Attitude provides the fundamental mind-set as a member of Anritsu Group in conducting
corporate activities. We should keep this mind-set to pursue corporate activity based on "Sincerity,
Harmony, and Enthusiasm", comply with each specific provision of this Code later described in chapter 2.

We will promote fair and sound corporate activities by observing applicable laws, this Code, and company
policies along with corresponding fundamental policies and manuals.

We will respect each and every person's human rights, and will not discriminate or impair personal
dignity. Moreover, we will not allow any forced labor or child labor.

We will contribute to the development of the international community and the local community by
respecting its customs and cultures.

We will reduce the impact of our business operations on the global environment and contribute to
building a sustainable society.

We will earn satisfaction and reliability by providing products and services that are useful to society and
by giving due consideration to the quality, safety, and environment.

We will engage in fair, transparent, and free competition, maintain a healthy relationship with politics,
government, citizen, and organizations.

We will improve transparency of corporate activities by disclosing business information fairly and in a
timely manner.

We will properly manage personal information and information assets including customer information.

We will act sincerely with responsibility, awareness, and integrity, continually improve corporate culture
of the organization as a member of the Anritsu Group.

1.3 Observance Responsibility

We shall sincerely implement the guidelines set forth in this Code. Executive officers and managements
shall, at all times, advise employees to abide by this Code and keep higher ethics and awareness to
abide by the laws to serve as a model for all the other employees.

In order to take concrete action in according with this Code, Anritsu Group (each company) should
continuously develop educational and enlightenment campaign by reinforcing the company regulations
and manuals etc.

Disciplinary action shall be taken when your action is in violation with this Code and falls under the grounds
for such action stipulated in the company employment regulation. Furthermore, when your intentional or
negligent action cause damage to Anritsu, you may be personally liable for the damages.

Chapter2: Relation with People

2.1 Respect of Human

We will respect every person's fundamental human rights from a defender of human dignity standpoint,
eliminate prejudice, and will not discriminate depending on race, nationality, religion, creed, sex, age,
social status, or disabilities whether mental or physical.

We will respect each and every individual's personality, and will not accept any discriminatory languages
or behaviors, sexual harassment, or any kind of harassment which would result in hurting other people's
personality.

We will develop deeper understanding and act towards human respect through various educational
programs.

2.2 Protection of Personal Information

We will take every step to protect personal information by respecting each and every individual's privacy,
abide by relevant laws and regulations concerning personal information, and properly handle personal
information.

2.3 Maintenance of Working Environment

We will strive to improve our working environment by keeping the workplace safe and hygienic, and will
keep each individual's work-life balance to maximize his or her potential.

Chapter3: Relation with Society

3.1 Relation with International Society and Community

We will abide by the international rules and laws of each country we do business with, respect their
cultures and customs as well as cooperate with the international society and development of the local
community.

We will contribute to the local development by cooperating with the local community.

3.2 Environmental Management

We will realize the social responsibility of a corporation to protect the environment, and we will individually
act according to decision based on environment friendliness to building a recycle-oriented society by
reducing harmful substances, preventing global warming, and being considerate in the life cycle of a
product including product development, purchasing, production, distribution, logistics, use at customer
site, recycling, and waste.

3.3 Contribution / Political Contribution / Political Activity

We will sufficiently consider the necessity and validity, abide by relevant laws and regulations when we
decide to make donations as part of our social contributions.

We will abide by relevant laws and regulations concerning politics, election, or political activity when we
deal with these activities.

3.4 Correspondence to Antisocial Influence

We will take decisive action, avoid all contacts, and will not support any activity which would promote
antisocial influences or any organization jeopardizing safety of civil society.

Chapter4: Relation with Customers, Suppliers and Competitors

4.1 About Business Activities

We will continuously provide creative, high level products and services that would satisfy the needs of our
customer by observing laws and regulations relating to business activities, and by committing to fair
business practices in accordance with sound business practices and social norms.

4.2 About Products and Service

We will provide a useful, high quality products and services with our "Original and High-Level" technology
to satisfy customers and society. We will also provide safe products that does not cause harm or threat
to human life, human body, or property due to defects in the product.

4.3 About Procurement

We will observe laws and regulations relevant to material purchasing, and will practice fair trade as well
as purchase materials and services at an appropriate quality, price, and delivery time.

We will conduct our material purchasing based on sound commercial practices and strive to work
together with our business connections for mutual harmony and benefits. We will not abuse our
dominant bargaining position over our business connections, or seek any personal benefit relating to
work.

4.4 Observance of Antimonopoly Law etc.

We will conduct fair business activities by observing laws and regulations relevant to promotion of fair
trading such as Anti-Monopoly Act.

We will not engage in any activities such as bid rigging or cartel which restricts fair and free competition,
or any activities which might be considered as us been engaged in such activities.

We will not practice exclusion of distributors etc., unjust discriminatory treatment, or any type of unfair
transaction such as restricting business activities.

4.5 Observance of Export & Import Related Regulations

We will observe relevant laws and regulations of home and abroad concerning Foreign Exchange and
Foreign Trade Law, Customs Act etc., and firmly manage in accordance with the procedure of internal
regulations (ICP, FOCP, GECP, etc.).

4.6 Disclosure

We will make every effort to gain proper understanding and acceptance from the society by broadly
communicating Anritsu group's company philosophy, company vision, and company policy.

We will make timely and accurate disclosure of Anritsu group's business information to stockholders,
investors etc., in accordance with the relevant laws and regulations.

4.7 Advertisement Activities

We will improve our understanding and trust from the customers by improving brand value of Anritsu and
Anritsu products through advertisement activities based on the company philosophy, company vision,
company policy, and the business strategy of Anritsu Group.

We will not allow inaccurate display or expression that might lead to false recognition of Anritsu group's
products and services.

4.8 Correspondence to Entertainment and Gifts

We will maintain moderation and comply with the sound business customs and social norm on business
entertainment, giving or receiving gifts from business connections.

We will not bribe, provide illegal payoffs, or provide any type of offerings without reasonable grounds to
any type of public officials including foreign public officials.

4.9 Observance of Anti-Money Laundering Related Laws and Regulations

We will observe Anti-Money Laundering (the laundering of illicit funds gained through criminal activities, etc.) related laws are regulations of each country.

Chapter5: Relation with Corporation

5.1 Proper Accounting and Operating Processing

We will perform proper accounting abiding by relevant laws and company regulations.

We will accurately prepare and properly save all the various records of finance and accounting. We will
not perform improper accounting or any other means which would cause damage to the company.

5.2 Prohibition of Conflict of Interests Action

We will not perform any action which is a conflict of interest to the company

5.3 Management and Proper Use of Corporate Property

We will properly manage our company assets based on company regulations. We will not use company
assets for personal benefit but only for the purposes of conducting our company business.

5.4 Management of Information

We will properly protect and manage information assets including Anritsu's trade secret, abide by laws
and company regulations concerning information.

We will not disclose, falsify, or make fraudulent use of our trade secret either during or after the term of
employment.

We will respect trade secrets of third party's including customer, business connection, or competitor, and
will not obtain or use information illegally, or use other than the purposes as intended.

5.5 Proper Use of Information System

We will properly utilize information system and protect from leaking company's trade secret, personal
information, and information provided by the customers.

We will use and manage personal computer and other equipments provided by the company in
accordance with the company procedures to prevent from any theft or loss.

We will not use our personal private computer or any other electronics to conduct our work to keep
unintended disclosure of business information.

We will not transmit information over the internet or intranet which would degrade company image and
credibility, any false acusation to others leading to discrimination.

We will not use Anritsu's network for personal trading (stock, auction or the like) or visit internet sites
containing inapproriate contents.

5.6 Prevention of Insider Trading

We will observe laws related to transaction of financial commodities. We will not trade stocks, bonds or
the like, based on Insider Information.

5.7 Protection of Intellectual Property Rights

We will proactively engage in creative activities to strengthen our intangible assets. We will also expand,
strengthen, and protect intellectual property rights by utilizing those rights of our company.

We will observe laws related to intellectual property rights ("Patent", "copy right law", etc. ), and respect
third party's intellectual property rights. We will not infringe any of these rights or make illegal copies of
computer software.

Chapter6: Report (Helpline)

6.1 Report

When you recognize any action that is in violation or the possibility of violating any of the provisions of
this Code, you should report through your supervisor or directly by utilizing the Helpline. The contact will
be Anritsu Corporate Ethics Promotion Committee (Legal Dept.) or contact established by each Anritsu
group company. You may directly report to the relevant department depending on the situation.

You should immediately report to the president of ANRITSU CORPORATION, executive officer in charge
of compliance, Legal Department, or the President of each group company when it is an emergency or
when the incident may cause serious damage to the company.

If you feel uncomfortable reporting within the company, you may choose outside contact (attorney at law).

The content and fact of the report will be treated confidential and the reporter will not suffer any adverse
consequences whatsoever as a result of making the report.

6.2 Questions on Code of Ethics Interpretation

In our daily operations, we should always consider, including the possibilities, whether or not our action is
in violation of laws, company regulations, or any part of this Code. Always consider how the action
would be perceived by others. When you have concerns and do not know what to do, please escalate
your concerns to your supervisor or relevant department for advice. You may also consider using the
Helpline as your reporting channel.